Submission Number: 560891-00356
Received: 9/12/2012 2:42:37 PM
Commenter: Kathleen Grant
Organization: Evergreen Veterinary Hospital
Agency: Federal Trade Commission
Initiative: Request for Comments and Announcement of Workshop on Pet Medications Issues, Project No. P121201
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• What evidence exists to support a need for federal legislation requiring veterinarians to provide written prescriptions to their clients? Our practice follows the American Veterinary Medical Association (AVMA) guidelines on providing prescriptions to clients. Federal legislation is not required. People who do not follow their professional community’s guidelines are not likely to follow federal regulation either indicating a far greater challenge than simply not writing a prescription. Therefore legislation to require veterinarians to write prescriptions will simply put increased burden on the compliant.
• Is there a need for federal legislation requiring veterinarians to notify clients that they have the right to fill their prescriptions at the pharmacy of their choice? There is no need for federal regulation in this area. Our practice follows the AVMA guidelines on providing prescriptions to clients and educating clients on their ability to request a prescription. Federal legislation is not required. If a veterinarian will not provide a prescription the client often has the ability to seek out a veterinarian better suited to their needs. Today’s consumers are smart and savvy—let them influence the market place with their pocketbooks. If the big box retailers and on-line pharmacies with their multi-million dollar advertisement campaigns can’t overcome the influence of a simple country veterinarian it is probably because today’s consumers are: smart and savvy.
• How might the passage of H.R. 1406 affect price, consumer choice and other forms of competition in the pet medications market? The net effect is that consumers will pay more, substantially more! The price of medications may temporarily decline slightly, however, the overall cost of veterinary care (combined veterinary services and products plus increased administrative burden) will increase substantially. Any slight decrease in medication price will likely evaporate as soon as the big manipulators control the market.
The veterinary business model operates on a combination of sales of services and products. When you change the elements of the mix other elements are affected so that the business owner can (1) pay the bills and (2) maintain a reasonable return on investment. Reducing product (medication) sales will result in higher prices for both veterinary services and for the remaining products sold in the veterinary practice including emergency medication. (This is particularly true in the small practice. The average veterinary practice in the US has two (2) full-time equivalent veterinarians and ten (10) staff members. Typically small, but economical, amounts of medications are kept on-hand—reducing the sales volume will drive up cost on the remaining medications. Veterinary practices have high fixed costs and are capital intensive.) The net effect is that consumers will pay more in a distributed model (separate providers of veterinary services and veterinary-oriented medications) than in the current consolidated service/product model (veterinarian providing both services and products) with some product sales leakage. The higher the leakage the higher the net consumer cost will be.
• What risks or inefficiencies may be posed by prescription portability for pet medications? There are several very important points to consider:
1) The veterinarians understand the client’s current situation. The veterinarian can use their discretion to provide the best treatment for the patient taking into account the client’s situation (which is not always financially-based.) The veterinarian knows when a client does not pick up a prescription when filled in-hospital.
2) Medications intended for animals should be dispensed only by people trained in veterinary pharmacology. Most pharmacists do not have this training, are not required to obtain or maintain this training, and laws have not been established to require this training and associated licensing.